Privacy · Car Handovers

1.Who we are

1.1For the purpose of this Privacy Policy, “you” or “your” means any end user accessing the Platform and/or our Services, and “we”, “us”, “our” or “Auto Payments” means Auto Payments Limited, company number 17131954 with our registered office address at 78 York Street, London, United Kingdom, W1H 1DP.

1.2The following definitions shall apply in this Privacy Notice:

Terms and Conditions: the terms and conditions for the use of the Platform and/or Services, available at www.carhandovers.com/terms, as may be updated from time to time.

Business: means any company, partnership, sole trader, organisation or other entity using the Services.

Services: the services provided through the Platform to users and Business customers pursuant to the Terms and Conditions, together with any related services we may provide from time to time.

Platform: the software platform through which we provide the Services to users and Business customers.

2.Processing Personal Data

2.1By using or accessing the Platform, or communicating with us, you understand and agree that we will collect and process your personal data in accordance with this Privacy Policy. If you do not agree with this Privacy Policy you must not access or use our Platform or Services.

2.2This Privacy Policy gives you information about how we collect and use your personal data through your use of the Platform, including any personal data you may provide when you contact us.

2.3Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we collect, use and protect it.

2.4Our Platform is not intended for children and we do not knowingly collect data relating to children.

2.5We are the controller and responsible for your personal data in this Privacy Policy.

3.Personal data we collect

3.1Information you provide. This may include:

3.1.1User profile: your first and last name, your email address and phone number, the name of the business you work for (if applicable), your password. This information is used to create your user account and allow you to create, access, manage and use your organisation's account and the Services.
3.1.2User content: this includes Vehicle handover information submitted through the Services, including vehicle registration details, vehicle condition information, damage records, photographs, videos, electronic signatures, generated PDF reports and any other information uploaded to the Platform by authorised users.

3.2Information created when using our Platform. This may include:

3.2.1Marketing data: your preferences in receiving marketing from us, and our third parties. We may also use our correspondence with you to generate information on how you respond to email, phone, messaging, social media, text and post campaigns.
3.2.2Communication data: we communicate with users by phone, email, and through the Platform. We keep a record of this correspondence.
3.2.3Device information: we may collect data on the device you use to access the Platform such as IP address, device ID and device information, and when using the Platform, your battery level.

3.3We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your device information to calculate the percentage of users accessing a specific feature of our Platform, for research and analytics, benchmarking, etc.. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

3.4We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

4.If you fail to provide Personal Data

4.1Where we need to collect Personal Data by law, or under the terms of a contract we have with you or a Business customer, and you fail to provide that data when requested, we may not be able to perform the contract or provide the Services. In that case, we may notify you and, where applicable, the relevant Business customer.

5.How we use your personal data

5.1We use your personal data for several purposes and in accordance with the law.

5.2Most commonly, we will use your personal data in the following circumstances:

5.2.1where it is necessary for our legitimate interests (or those of a third party, such as a Business customer where applicable) and your interests and fundamental rights do not override those interests;
5.2.2where we need to comply with a legal obligation; or
5.2.3where you have provided consent for us to do so.

6.Purposes for which we will use your Personal Data

6.1We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our or third parties; legitimate interests are where appropriate.

6.2Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Where more than one ground has been set out in the table below, please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To set up an account on the Platform, verify your identity and, where applicable, your authority to act on behalf of a Business customer.	(a) User profile (b) Communication Data	Necessary for our legitimate interests and, where applicable, the legitimate interests of a Business customer to ensure that authorised users can access and use the Services.
To provide you with customer support when using the Platform. This will also include to direct your questions to the appropriate customer support person, to investigate and address your concerns and to monitor and improve our customer support responses.	(a) User profile (b) Communication Data	Necessary for our legitimate interests and, where applicable, the legitimate interests of a Business customer to ensure users can benefit from the Services. Necessary for our legitimate interest to ensure that the Services are performing to the required standard and any issue is resolved Necessary to comply with a legal obligation
To provide, operate, maintain and improve the Services, including the creation, storage and management of vehicle handover records, photographs, videos, electronic signatures and PDF reports	User profile User content Communication Data Device Information	Necessary for our legitimate interests to provide and improve the Services, monitor their safe and lawful use and protect our business and reputation. Necessary to comply with a legal obligation
To manage our relationship with you and any Business customer associated with your account (where applicable) which will include notifying you about any changes to our Terms and Conditions or this Privacy Notice, and/or notifying you about changes to our Services	(a) User profile (b) User content (d) Marketing data (e) Communication Data	Necessary to comply with a legal obligation (to comply with the transparency requirements under data protection legislation). Necessary for our legitimate interests to keep customers informed about the Services.
To administer and protect our business, and the Services and use data analytics to improve them (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), and for research and marketing purposes.	(a) User profile (b) Device Information (d) Marketing data (e) Communication data;	Necessary for our legitimate interests to run our business, for the provision of administration and IT services, network security, to prevent fraud, to analyse usage trends to improve the user experience and enhance the safety and security of our services
To deliver relevant marketing content and make suggestions and recommendations to you about goods or services that may be of interest to you, including products, services, promotions, surveys, news, updates, and events.	(a) User profile (b) Marketing data	Necessary for our legitimate interest to keep you informed of new features in our Services or of our other similar services or goods which would be of interest to you Consent (where required by law).
Dealing with legal disputes, claims or other legal or administrative or regulatory actions or investigations relating to the Services, vehicle handovers or reports generated through the Services	User profile User Content Device information Communication data	Necessary to comply with legal obligations Necessary for our legitimate interests to establish, exercise or defend legal claims and to protect our business from legal, regulatory and reputational risk.

6.3In this Privacy Notice

6.3.1Consent means your active agreement to use your personal data for a specified purpose. We will only process your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
6.3.2Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you and our customers the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where we assess our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
6.3.3Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

7.Marketing

7.1Where you have provided your consent, we may also use your contact details to promote and send you relevant ads and content about our Services. Where applicable, we may ask you for your consent to provide you with marketing emails or other form of communication from third parties.

7.2You may unsubscribe from any of the above communications at any time by clicking on “unsubscribe” at the bottom of any of our marketing communication, or by writing to us at support@carhandovers.com.

8.Change of purpose

8.1We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

8.2If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

8.3Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9.Sharing your data

9.1Your personal data may, for the purposes set out in this Privacy Policy, be disclosed for processing to:

9.1.1third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them;
9.1.2to any third party where such disclosure is required in order to enforce or apply any contracts we have in place, or to protect the rights, property, or safety of our company, our customers, our employees or contractors, or others but always in accordance with applicable laws; and/or
9.1.3protect the rights, property or safety of our company, our customers, our employees, our contractors, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

9.2We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

10.International transfers

10.1Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented by implementing appropriate safeguards. These may include:

10.1.1entering into contractual agreements that impose strict data privacy and security obligations (e.g. the European Commission’s Standard Contractual Clauses or the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses). You may request a copy of these safeguards by contacting us using the contact details set out below;
10.1.2applying technical and organisational security measures (such as encryption, access controls, and data minimisation protocols);
10.1.3conducting data transfer risk assessments or legal evaluations, where required under applicable laws; and/or
10.1.4relying on the explicit consent of the individual, where permitted or required under relevant law.

11.Data security

11.1We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

11.2We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11.3We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

11.4We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.

12.Data retention

12.1We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

12.2Vehicle handover records, photographs, videos, electronic signatures and generated PDF reports are generally retained for a period of two years from the date of the relevant vehicle handover, following which they may be deleted or anonymised unless a longer retention period is required by law or is otherwise necessary in connection with a complaint, dispute or legal claim.

12.3We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

13.Your legal rights

13.1You have a number of rights under data protection laws in relation to your personal data.

13.2You have the right to:

13.2.1Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
13.2.2Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
13.2.3Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
13.2.4Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
13.2.5Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
13.2.6Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

●If you want us to establish the data's accuracy;
●Where our use of the data is unlawful but you do not want us to erase it;
●Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
●You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

13.3If you wish to exercise any of the rights set out above, please contact us using the contact details below.

14.What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

15.Contact details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us at: Support@carhandovers.com.

16.Changes to the Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated in September 2026.

17.Third-party links

Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the Privacy Policy of every website you visit.

18.Complaints

18.1If you have any concerns about how we collect, use or process your personal data, please contact us in the first instance using the contact details set out in this Privacy Policy.

18.2We will investigate your complaint and respond in accordance with applicable data protection laws and our complaints procedures.

18.3If you remain dissatisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection matters (www.ico.org.uk).

18.4We would, however, appreciate the opportunity to address your concerns before you approach the ICO and therefore encourage you to contact us first.